Case Laws
Case Laws
This case focused on the bonded labor system and the right of bonded laborers to live with dignity
under Article 21 of the Constitution. The petitioner, a public interest group, highlighted the
exploitative working conditions of laborers in stone quarries. The Supreme Court invoked socio-
economic rights to ensure protection for the marginalized.
From a Hohfeldian perspective, the judgment recognized the claim-right of bonded laborers to be
free from exploitation and inhumane working conditions. Correspondingly, the state and employers
were burdened with the duty to eliminate bonded labor and ensure humane work conditions under
the Bonded Labour System (Abolition) Act, 1976.
The state’s earlier negligence in enforcing labor laws implied a breach of its duty, as bonded laborers
had a correlative right to legal protection and fair working conditions. The Court's directives imposed
a renewed duty on the state to rehabilitate and provide welfare measures for former bonded
laborers. By recognizing the socio-economic rights of workers, the Court also shielded their
immunity-right from any further exploitation or coercion.
This case involved allegations of the exploitation of construction workers engaged in the Asian
Games project in Delhi. The court interpreted constitutional rights under Articles 14, 19, and 21 to
protect workers' interests.
Applying Hohfeldian analysis, the judgment highlighted the claim-right of workers to fair wages and
decent working conditions. This imposed a duty on both private employers and the state to ensure
the proper implementation of labor welfare legislation, such as the Minimum Wages Act and
Contract Labour Act.
The Court extended the understanding of the right to life under Article 21 to encompass humane
conditions of work, thus reaffirming workers’ liberty-right to employment without exploitation.
Employers were stripped of their power to impose unlawful terms, as these workers now had an
immunity-right against arbitrary and exploitative practices.
This case established guidelines for the protection of individuals from custodial torture and deaths.
The Court emphasized the importance of procedural safeguards under Articles 21 and 22 of the
Constitution.
From a Hohfeldian perspective, the judgment established the claim-right of detainees to humane
treatment and procedural fairness. Corresponding to this was the duty of law enforcement agencies
to respect these rights by following the arrest and detention guidelines outlined by the Court.
The decision also reinforced an immunity-right for citizens against custodial violence, rendering the
police powerless to arbitrarily infringe upon fundamental rights. This judgment imposed a positive
duty on the state to ensure the training of officers and the maintenance of transparent arrest records
to prevent abuse.
4. KS Puttaswamy v. Union of India (2017)
In this landmark case, the Supreme Court declared the right to privacy as a fundamental right under
Article 21.
Hohfeldian analysis reveals the affirmation of a claim-right for individuals to protect their personal
information and private life from state and non-state actors. Correspondingly, the state now had a
duty to refrain from actions that unjustifiably intrude on this right.
The Court also acknowledged individuals' immunity-right against state surveillance without lawful
authority, effectively stripping the state of its power to arbitrarily access private data. The judgment
imposed a positive duty on the state to implement robust data protection measures, ensuring the
autonomy of individuals over their information.
This case addressed the forced eviction of pavement dwellers in Bombay, with the Court recognizing
the right to livelihood as an essential component of the right to life under Article 21.
In Hohfeldian terms, the judgment recognized the claim-right of pavement dwellers to livelihood,
correlating with the duty of municipal authorities to avoid arbitrary evictions. The state was obligated
to provide alternative housing or compensation before carrying out evictions.
Furthermore, the Court reinforced an immunity-right for the poor against unreasonable and arbitrary
state action that endangered their livelihood. The judgment redefined the power of the state,
limiting it to actions in compliance with constitutional protections.
This case dealt with environmental degradation caused by the discharge of untreated effluents by
tanneries in Tamil Nadu. The Court established the "precautionary principle" and the "polluter pays
principle."
Through a Hohfeldian lens, the judgment recognized the claim-right of citizens to a clean and healthy
environment, imposing a duty on industries to adopt eco-friendly practices. The state, as a trustee of
natural resources, also bore a duty to regulate and monitor industrial activities.
The Court’s directives granted citizens an immunity-right from environmental harm caused by
reckless industrial activities, thereby limiting the power of industries to pollute without
accountability.
This landmark judgment addressed the issue of sexual harassment of women at the workplace. The
Supreme Court laid down comprehensive guidelines for employers until legislation was enacted,
which later led to the Sexual Harassment of Women at Workplace (Prevention, Prohibition, and
Redressal) Act, 2013.
From a Hohfeldian perspective, the judgment recognized women’s claim-right to work in a safe
environment free from harassment. This imposed a duty on employers to create mechanisms for
preventing and addressing sexual harassment, including grievance redressal systems.
The judgment also reinforced women’s immunity-right against being subjected to any form of
discrimination or harassment, thus limiting the power of male employees or superiors to exploit
workplace hierarchies. The state’s duty to safeguard these rights was highlighted through the
directive for the formation of complaint committees and training programs.
This case struck down Section 66A of the Information Technology Act, 2000, as unconstitutional due
to its vagueness and chilling effect on freedom of speech.
Through a Hohfeldian analysis, the Court reaffirmed individuals' claim-right to free speech and
expression under Article 19(1)(a). Correspondingly, the state had a duty not to impose arbitrary or
vague restrictions on this right.
The Court also recognized individuals’ immunity-right against state censorship that lacks reasonable
grounds. This judgment curtailed the power of authorities to criminalize online speech without clear
and justifiable cause.
9. Indian Young Lawyers Association v. State of Kerala (Sabarimala Temple Case) (2018)
This case dealt with the exclusion of women of menstruating age from entering the Sabarimala
temple. The Supreme Court held that such exclusion violated constitutional principles of equality and
non-discrimination.
From a Hohfeldian perspective, the judgment recognized women’s claim-right to access religious
spaces without discrimination. This imposed a duty on temple authorities and the state to ensure
equal access.
The Court negated the liberty-right of religious authorities to impose exclusionary practices based on
gender, thereby reinforcing women's immunity-right against discriminatory religious customs. The
decision limited the power of religious institutions to violate fundamental rights.
This judgment decriminalized consensual same-sex relationships by reading down Section 377 of the
Indian Penal Code.
Hohfeldian analysis reveals the affirmation of individuals' claim-right to express their sexual
orientation without fear of criminal prosecution. The state correspondingly lost its power to interfere
with private consensual relationships among adults.
The Court also recognized individuals’ immunity-right against state-sanctioned discrimination based
on sexual orientation, thereby reinforcing constitutional guarantees of equality and dignity.
Hohfeldian Analysis:
Patients possess a claim-right to receive emergency medical treatment, which correlates
with the duty of doctors and healthcare institutions to provide prompt care without waiting
for legal formalities such as police involvement or legal compliance.
The judgment rejected the liberty-right of hospitals to deny treatment based on
administrative concerns, reinforcing a duty that aligns with the right to life under Article 21
of the Constitution.
The case addressed environmental degradation caused by tanneries in Tamil Nadu and led to the
adoption of the 'Precautionary Principle' and 'Polluter Pays Principle.'
Hohfeldian Analysis:
The public holds a claim-right to a clean and safe environment, which imposes a duty on
industries to adhere to environmental regulations and use sustainable practices.
The state has a corresponding duty to regulate industrial activities and mitigate pollution.
The decision limited the power of industries to pollute and granted the public an immunity-
right from industrial hazards that endanger health and biodiversity.
This case addressed police harassment and the need for procedural fairness during criminal
investigations.
Hohfeldian Analysis:
Citizens hold a claim-right to be treated fairly during investigations, which correlates with the
duty of law enforcement agencies to avoid harassment and ensure constitutional safeguards
such as due process.
The state’s duty to protect individual dignity curtailed the liberty-right of law enforcement to
engage in arbitrary or coercive practices during investigations.
The case reinforced the right to pollution-free water as part of the right to life under Article 21 of the
Constitution.
Hohfeldian Analysis:
Citizens hold a claim-right to access pollution-free water for drinking and daily use, imposing
a duty on the state to prevent industrial pollution and enforce environmental regulations.
Industries have a duty not to discharge pollutants into water bodies. The decision granted
the public an immunity-right from the adverse consequences of environmental degradation
caused by industrial activities.
5. Shoba Vittal Kolte v. State of Maharashtra (2020)
This case dealt with arbitrary demolition of property by state authorities without proper notice or
adherence to due process.
Hohfeldian Analysis:
Property owners hold a claim-right to protection against arbitrary demolition, which
correlates with the duty of state authorities to follow due process, provide notice, and allow
representation.
The court restricted the power of municipal authorities to engage in summary demolitions
without procedural compliance, thereby reinforcing the immunity-right of property owners
from unfair treatment.
The judgment highlighted the need for fair and adequate compensation during land acquisition for
public purposes.
Hohfeldian Analysis:
Landowners have a claim-right to just and adequate compensation when their land is
acquired, imposing a duty on the state to act fairly, comply with statutory requirements, and
ensure prompt payment.
The decision curtailed the power of the state to acquire land arbitrarily, granting landowners
an immunity-right against unfair or inadequate compensation mechanisms.
This landmark case reinforced the right of an accused person against self-incrimination during
criminal proceedings.
Hohfeldian Analysis:
Accused persons hold an immunity-right against being compelled to incriminate themselves,
imposing a duty on investigative agencies to respect their right to remain silent and not
coerce confessions.
The state’s duty to uphold constitutional protections under Article 20(3) limits its power to
compel self-incrimination, thereby safeguarding individual liberties during criminal
investigations.